Confidentiality claims for Project EnergyConnect

Confidentiality claims for Project EnergyConnect

Contingent Project Application for Project EnergyConnect

30 September 2020

ii | Confidentiality claims

1 | Confidentiality claims

Confidentiality Claims

This document identifies confidential information in our Contingent Project Application (Application) for the

Project EnergyConnect for the 2018-19 to 2022-23 (2018-23) regulatory period.

The attachments and models that comprise our Application are listed in Table 1, which also identifies which

documents and models contain confidential information.

Table 1 – Documents and models comprising this Application (excluding our other supporting documents)

Document / model number

Name Confidential information

A.1 PEC Principal Application document No

A.2 Stakeholder engagement overview No

A.3A PEC Post-Tax Revenue Model – (BAFO outcome) No

A.3B PEC Post-Tax Revenue Model – (Financeability Rule change) No

A.3C PEC Post-Tax Revenue Model – (Revenue adjustment) No

A.4 Specification and scope for PEC No

A.5A Supplementary Capex forecasting methodology for PEC (BAFO capex forecast)

Yes

A.5B Capex Forecasting Methodology for PEC (RFT Phase A capex forecast)

Yes

A.6 Capex Model for Project EnergyConnect Yes

A.7 Corporate and network overhead forecast for Project EnergyConnect

Yes

A.8 Corporate and network overhead spreadsheets for Project EnergyConnect

Yes

A.9 GHD, Independent capex Assessment for the BAFO Outcomes, September 2020

Yes

A.10 HoustonKemp, Independent capex Assessment for the BAFO Outcomes, September 2020

Yes

A.11A FTI Consulting, Assessing the Benefits of interconnectors, September 2020

No

A.11B FTI Consulting, Benefits of PEC, June 2020 report Yes

A.12 Opex forecasting methodology for Project EnergyConnect Yes

A.13 Opex model for PEC Yes

A.14 Insurance for Project EnergyConnect Yes

A.15 Demand forecast model Yes


Document / model number

Name Confidential information

A.16 Model changes No

Table 2 sets out the confidential information in the documents and models that comprise our Application

together with the reasons why we consider this information to be commercial-in-confidence. This document has

been prepared in accordance with the Australian Energy Regulator’s (AER) Confidentiality Guideline.


Table 2 – Confidential information in our PEC Application

Title page and paragraph number Description of

the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

A.1 PEC – Contingent Project Application - Principal Application document, 29 June 2020

– Table 1 – ‘Documents and

models comprising this

Application (excluding our other

supporting documents)’, p. 6

Capex Insurance report Market sensitive cost inputs

Public disclosure could potentially harm TransGrid’s and the third-party’s commercial interests.

Revealing personal information and unit rates for procuring particular types of materials or services could set a floor in the market when procuring such services in the future

While the detriment of publishing the information is clear, we are not aware of any public benefit in publicly disclosing this information that could outweigh the detriment.

A.5A Supplementary capex Forecasting Methodology

– Table 4.1 – ‘RFT Phase A

Capex by category’, p. 12-13

– Section 5.3 – ‘Indirect capex’

p.34

– Table 5.13 – ‘Revisions to

indirect capex’ p. 36

– Table 7.1 – ‘Capex by

category’, p. 41

Capex Indirect capex insurance costs

Market sensitive cost inputs


Revealing personal information and unit rates for procuring particular types of materials or services could set a floor in the market when procuring such




the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

services in the future

– Table 5.1 – ‘BAFO capex

forecast for tendered works’, p.

20

– Table 5.4 – ‘Other opex costs

not included in tender prices’, p.

23

Capex Bidder 1 information – unsuccessful bidder





A.5B Capex Forecasting Methodology for PEC 29 June 202

– Section 6 – Forecast capex for

tendered works

Capex Forecast capex for tendered works

Superseded Superseded by the BAFO outcome for tendered works explained in section 5.1 of the Supplementary Capex Forecasting Methodology

Not relevant because superseded by BAFO outcome for tendered works explained in section 5.1 of the Supplementary Capex Forecasting Methodology

Not relevant because superseded by BAFO outcome for tendered works explained in section 5.1 of the Supplementary Capex Forecasting Methodology

– Section 8.7.1, p.70 Capex Indirect capex insurance costs


Public disclosure could potentially

Revealing personal

While the detriment of



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– Table 8.7 – ‘Project insurance

costs’ p. 71

– Table 11.1 Capex forecast by

category, p.80

harm TransGrid’s and the third-party’s commercial interests.

information and unit rates for procuring particular types of materials or services could set a floor in the market when procuring such services in the future

publishing the information is clear, we are not aware of any public benefit in publicly disclosing this information that could outweigh the detriment.

A.6 PEC Capex Model

– Cells K34:Q38, S40, K42:Q42,

K72, K74, K80:K81, N80,N81,

K83, N83, and K88 of the Inputs

sheet

– Cells D185:D188 and D208 of

the Outputs sheet

Capex Tendered costs Market sensitive cost inputs




A.7 Corporate and network overhead - BAFO

– Section 9 pp.33-34 Capex Insurance costs Market sensitive Public disclosure could potentially harm TransGrid’s

Revealing personal information and

While the detriment of publishing the



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– Table 10.1 –‘ Forecast capex

for insurance during

construction’, pp.33-34

– Section 12 Reference material

and the third-party’s commercial interests

unit rates for procuring particular types of materials or services could set a floor in the market when procuring such services in the future

information is clear, we are not aware of any public benefit in publicly disclosing this information that could outweigh the detriment.

– Section 6.3.3.1 – ‘Property’ p.

15

Capex Property – location of preferred new office space

Strategic information

Public disclosure could potentially harm TransGrid’s commercial interests

Revealing this information could inhibit procuring the new office space at competitive rates


– Table 6.4 – ‘Project

Development – IT costs’, p.16-

17

Capex Project Development – IT costs

Strategic information


Public disclosure of contractor costs for particular types of materials or services could harm TransGrid’s business interests

While the detriment of publishing the information is clear, we are not aware of any public benefit in publicly disclosing this information



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

that could outweigh the detriment.

– Section 6.4.3, Table 6.11-

‘Project Development -

Summary of Consulting Cost

Estimate’ p. 21

Capex Assumptions Strategic information


Revealing this information could inhibit procuring the services at competitive rates


A.8 Corporate and network overhead forecast spreadsheet

The following tabs in the model:

– ‘Works Delivery Res Cost’

– ‘WD Resource schedule’

– ‘PD-Labour (&related)’

– ‘PD-Non Labour’

– ‘L&E-Labour (&related)’

– ‘L&E-Non Labour’

– ‘SHC-Labour (&related)’

This has staff names, contractor or consultant details, salary information and consultant fee estimates

Works Delivery, Project Development, Land and Environment, and Stakeholder and Community Engagement – labour and non-labour costs

Personal information


Information that is related to the individual staff members, contractors or consultants can be identified

Compliance with Privacy Law

Revealing this information could inhibit procuring these services at competitive rates

Public disclosure of this information could undermine the request for quote, request for tender and




the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– ‘SHC-Non Labour’ negotiating strategies to achieve efficient costs.

– s8. Insurance’ – Cells E4:F4 Capex Insurance costs Market sensitive Public disclosure could potentially harm TransGrid’s and the third-party’s commercial interests.



A.9 – GHD – independent engineering verification and assessment

– p.85 Capex Insurance information

Market sensitive Public disclosure could potentially harm TransGrid’s and the third-party’s commercial interests

Revealing personal information and unit rates for procuring particular types of materials or services could set a floor in the market when procuring such




the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

services in the future

A.10 – HoustonKemp – independent economic verification and assessment

– Table 4, p.14 and paragraphs 2

and 3, p.24

Capex Bidder 1 information – unsuccessful bidder





– Section 9.1.6, p.44 Capex Insurance costs Market sensitive Public disclosure could potentially harm TransGrid’s and the third-party’s commercial interests





the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

A.11B – FTI Consulting, Benefits of PEC, June 2020 report

– p.3 last paragraph, p.14

second last paragraph, p.93

paragraph 4.71, p.94 paragraph

4.73 and p. 95 Table 4.2 and

paragraph 7.74

Prices SA Price impact Other Not relevant because ElectraNet has its own expert report on this matter

Not relevant because this information is provided by ElectraNet


A.12 - Opex forecasting methodology

– Table 3.2 – ‘Forecast

incremental opex for PEC by

component’, p.5

– Footnotes 7 and 8 p. 6

– Section 4.3 - ‘Robust approach

to determining forecast

incremental opex’, p.7

– Section 4.4.3 – ‘Insurance

costs’, p.13

– Table 4.4 – ‘Incremental

insurance related opex’, p.13-14

Opex Insurance Market sensitive cost inputs






the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

Footnote 17, p.13

– Table 4.1 – ‘Maintenance

activity’ column, p.9

Opex Maintenance Market intelligence

Details of maintenance plans for the assets

Public disclosure of this information could undermine TransGrid in future negotiations with suppliers.


A13. Opex Model

– Inputs’ – Cells C30:C48, Cells

F30:F48, and Cells M30:M48

Opex Maintenance Market intelligence

Details of maintenance plans for the assets





the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– ‘Inputs’ – Cells P30:Q48 Opex Maintenance Market sensitive cost inputs

Details of maintenance task unit rates

Revealing unit rates for procuring particular types of materials or services could set a floor in the market when procuring such services in the future


– ‘Inputs’ – Cells C80 and O82 Opex Insurance Market sensitive cost inputs




A.14 Insurance report

– p.4, table 2 and paragraphs 2

and 4

Opex Insurance Market sensitive cost inputs

Public disclosure could potentially harm TransGrid’s

Revealing personal information and

While the detriment of publishing the



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– p.15 to 17 - ‘ summary of

premium estimates’

– p.28, Appendix 5

and the third-party’s commercial interests.

unit rates for procuring particular types of materials or services could set a floor in the market when procuring such services in the future

information is clear, we are not aware of any public benefit in publicly disclosing this information that could outweigh the detriment.

A15. Demand Forecast Model

– All sheets Detailed flow data by date, hour and direction

Forecast demand Market intelligence

Details of asset usage



Other supporting documents

Memo - Revised estimate of EnergyConnect Biodiversity Offset Liability and Update to Strategy



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– Section 1.1 – ‘Overview’ p.1,

paragraph 4

– Section 4.2 ‘Mixed offset option

combining BCF payment with

BSA’, p.7,

– Working Maps 1 – 7 (no page

references)

– Section 5 – ‘Key risks to

biodiversity offset liability

estimate ‘ (paragraphs 4 and 5)

p. 16

– Table 7.1 – ‘Summary of likely

biodiversity offset liability for

recommended BOS approach’

p. 20

– Section 7.1 – ‘Maximum

biodiversity offset liability

estimate’ (paragraph 2) p. 20




p. 21

– Appendix A – Previous offset

scenario advice

Private property and ownership identifiers

Privacy information

Personal Information

Information (property names, descriptors, and ownership names) would make private landowners readily identifiable

TransGrid is subject to a confidentiality clause within its property negotiation agreements. This currently applies to agreements negotiated for Tareena and Big Bend properties

TransGrid does not have permission from these landowners to release privacy information.

Revealing privacy data would compromise TransGrid’s position to negotiate a fair market price with identified landowners.


Removal of privacy information has no material impact on understanding the estimated biodiversity offset liability.

Releasing this information could result in property specific market inflation for TransGrid negotiations – Capex impacts.

Appendices A & B, which outline an earlier estimate and includes privacy information, is not required for current estimate explanation.



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– Appendix B – Offset liability

after BSA establishments

– p. 7, section 4.2.1, paragraph 3

– Table 4.1 ‘Summary of target

PCTs corresponding with most

significant residual ecosystem

credit liabilities’ p. 8

– Table 4.4 ‘Summary of Key

Drivers for Offsets Liabilities’

(second row) pp. 13-14. 14,




p. 20




p. 21

– Section 8 – Biodiversity offset

liability estimate assumptions

and limitations, p. 22 (last main

bullet point)

– Appendix A – Previous offset

scenario advice

Information regarding the market value of offsets and properties considered for potential acquisition.

Sensitive commercial land acquisition information

Strategic Information

Commercial information related to value and strategy for land acquisitions.

TransGrid is subject to a confidentiality clause within its property negotiation agreements. This currently applies to agreements negotiated for Tareena and Big Bend properties

Public release would compromise TransGrid’s position to negotiate a fair market price for properties identified in strategy as preferred acquisitions.

Market will have information regarding TransGrid’s expenditure estimates, commercial strategy and risks

Releasing the information could result in market inflation for TransGrid negotiations – Capex impacts.

Appendix A which outlines an earlier estimate, and Appendix B which identifies offset values for specific properties, is not essential for current estimate explanation.



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– Appendix B – Offset liability

after BSA establishments

JLL Report Land Acquisition Costs Revised 25 August 2020

– p. 9, Table 6.0 Private property and ownership identifiers

Privacy information

Personal Information

Information (property names, descriptors, and ownership names) would make private landowners readily identifiable

TransGrid is subject to a confidentiality clause within its property negotiation agreements.


Revealing privacy data would compromise TransGrid’s position to negotiate a fair market price with identified landowners.


Removal of privacy information has no material impact on understanding the capex estimate.

Releasing the information could result in property specific market inflation for TransGrid negotiations – Capex impacts.

– p. 2, Table 1.0

– p. 3, Table 3.0

– p. 3, bottom set of bullet points

Information regarding the market value of potential property

Sensitive commercial land acquisition information

Strategic Information

Commercial information related to value and strategy for land acquisitions.

Public release would compromise TransGrid’s position to

Releasing the information could result in market inflation for TransGrid



the confidential

information

Topic of the

confidential

information

Confidentiality

category

Why the

confidential

information falls

into the selected

category

How and why

detriment would

be caused from

disclosing the

confidentiality

information

Why the

identified

detriment is not

outweighed by

the public

benefit

– p. 4, Table 4.0

– p. 7, paragraphs 3, 4, 10 & 11

– p. 8, paragraph 8 and list after

paragraph 10

– p.9, various values across page

– p. 9, Table 6.0

and easement acquisitions.

TransGrid is subject to a confidentiality clause within its property negotiation agreements.

negotiate a fair market price.

Market will have information regarding TransGrid’s expenditure estimates, commercial strategy and risks

negotiations – Capex impacts.